10/09/2019
*Certainly uncertain…*
News spread that Annual return and Reconciliation statement is going to be waived for those whose turnover is less than Rs. 5 Crores.
Just few days back, on 31.08.2019, when the due date is approaching for ITC-04 (already suffered so many extensions), the same was waived shockingly. I too accept that the industry took lot of pains for preparation and filing of it. Practically it had many implications. But rather simplifying it, it was altogether scrapped for 2017-18 & 2018-19. But what about those who have already spent tons of hours and tried and succeeded in filing? Late filers are saved ! Honest tax payers and complying dealers were not spared.
Now again the same anomaly was repeated.
✓How many no.of hours ??
Countless... What a time spent on annual returns. CAs burnt their oil midnight and put tons of efforts, attended seminars, webinars, lectures and finally our Institute had spent all the efforts and leave no stone unturned. Some explained. Some understood. Some criticized. Some recommended. But everybody participated and finally started filing. But what happened ultimately. Is it not crystal clear instance of lack of preparedness for implementation?
✓How many extensions?
Never ending. The extensions almost reached the due date for the next year (2018-19) annual return filing deadline. Why hide and seek? If something is perceived to be not possible to reach implementation, why not defer it / scrap it at the earliest. (Why after doing R&d on public and professionals?)
✓How much news?
Got the news of notification of forms, later amendments, later extension, extension, extension again and clarifications, press releases, 11th hour preparatory steps, calls from department regarding the status of annual returns, conducting rush end awareness campaigns by the dept., and finally achieved what …. Scarp it just like that.
✓Is early Compliance also a sin?
Many dealers spent countless hours on this so called annual return and filed with lot of efforts. Now undoing the ‘done’. Perhaps you won’t find in any other country. (Strictly I don’t know). Again late filers are spared. Early birds are hit.
✓Is Scarpping or removal is what required??
One can say YES if the other option of ‘simplification’ is ignored. Simplifying the form (rather one can say some tables) is another simple alternative to speed up the process which was not taken into account like in ITC-04
✓Is scrapping good instead of simplifying?
Annual return is best option to rectify errors. Errors are prone to occur especially when the law is new. So the requirement of annual return is more warranted in the initial years of implementation of new piece of legislation.
Where are we going??
Anyways, Hope for the Best ! ( What more can we expect in GST??)
Nirav Rami & Co.
Chartered Accountants
